Farmed Fish Health Framework proposed priority actions: EIR release

Information requested

To precede your request, you quoted the following text for context:

“Work Stream 4: Cleanerfish

Cleanerfish offer a sustainable and environmentally positive method for reducing the impact of sea lice on salmonid growth, and assessment of the potential contribution of wild caught and hatchery cultivated supplies relative to future demand is essential.

Activities

• Building on agreed management measures with the Scottish Government, define industry demand for farmed cleaner fish (wrasse and lumpfish) and the barriers to delivery.
• Map out required research and development, investment and timescale to deliver total industry demand.
• Review and assess the potential for cleanerfish use in rainbow trout cultivation.
• Assess whether management measures are appropriate and proportionate to the current and anticipated future levels of sustainable wild wrasse fishing in Scotland.
• Establish an international forum or platform in order to share cleaner fish husbandry best practice and establish best practice husbandry measures for the Scottish industry."

You then asked us three questions:

1. Has the Scottish Government carried out any review of the description of cleaner fish in the introductory paragraph quoted above?

2. What outputs can be identified for each of the Activities listed above?

3. In particular, what estimation exists of 'total industry demand'?

Response

Because you did not refer to either the Freedom of Information (Scotland) Act 2002 (FOISA) or the Environmental Information (Scotland) Regulations 2004 (EIRs) in your request, the Ministers’ Section 60 Code of Practice offers instructions on when it might be more appropriate to deal with a request for information as “business as usual”. We have determined that your questions 1 & 3 above met all three criteria which means it more appropriate, and helpful, to answer these out with the EIRs. Questions 2 does not meet the criteria and so has been answered under the EIRs.

We have provided a response to all three questions as part of the same response letter for your convenience.

Response to question 2 of your request under the EIRs

What outputs can be identified for each of the Activities listed above?

While our aim is to provide information whenever possible, in this instance the Scottish Government does not have the information you have requested. Therefore we are refusing your request under the exception at regulation 10(4)(a) of the EIRs. The reasons why that exception applies are explained below.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have. The Scottish Government does not have the information you have requested because we do not hold specific outputs for each of the activities listed in your request above.

This exception is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception.

While we recognise that there may be some public interest in information about the specific outputs for each of the activities listed in your request above, clearly we cannot provide information which we do not hold.

Additional information provided out with the EIRs in response to question 2 above:

Although we do not hold any written or recorded information on outputs specifically, in the interest of providing advice and assistance to you we offer the following.

The Farmed Fish Health Framework (FFHF), in its initial cleanerfish workstream set out a number of work priorities related to cleanfish use, wild fisheries management, knowledge exchange and possible use as a sea lice control measure within trout farming. While we do not hold outputs from these specific work activities, this work by the FFHF initiated activity that resulted in a number of developments within the umbrella of cleanerfish use.

The Scottish Government introduced mandatory measures in 2021 to regulate the wrasse fishery, including the requirement of a Letter of Derogation giving permission from SG’s Marine Directorate to fish under certain eligibility and conditions. We continue to collect data through these fishery measures, which builds the evidence base we use to make management decisions. The Scottish Government will undertake a Habitats Regulations Appraisal (HRA) and Appropriate Assessment (AA) for 2025, and the fishery is included within the Seafish Scoping exercise for non-quota species Fisheries Management Plan (FMP) planning.

Collaborative work has been undertaken to scale up production of farmed cleanerfish to increase the availability of captive bred wrasse and lumpfish. The Sustainable Aquaculture Innovation Centre previously supported projects on scaling-up farmed wrasse production in recognition of the potential benefits of sourcing from reared wrasse populations. Lumpfish were also successfully deployed with hatchery production increasing, in its early years we saw captive breeding increasing from 262,000 lumpfish in 2016 to 925,000 in a year.

Cleanerfish use with rainbow trout is not permitted as it represents an unacceptable biosecurity risk. This is due to the susceptibility of cleanerfish species (wrasse and lumpfish) and rainbow trout to viral haemorrhagic septicaemia (VHS), a listed disease. The position is administered by the Fish Health Inspectorate (FHI), on behalf of Scottish Ministers, through the authorisation conditions issued in accordance with the Aquatic Animal Health (Scotland) Regulations 2009.

The Salmon Scotland (formally known as the Scottish Salmon Producers Organisation) hosted an industry cleanerfish knowledge exchange day in May 2019, immediately followed by a scientific workshop to promote and share research within this field. In recent years, the Sustainable Aquaculture Innovation Centre has also hosted both an International Ballan Wrasse conference and an international lumpfish conferences, held in 2021 and 2022 respectively. These have provided valuable opportunities for knowledge exchange in support of cleanerfish use and production.

Response to questions 1 & 3 of your request

Please note that your right to request a review under the EIRs only applies to our response to question 2 above. The question below have been answered, out with the EIRs, as explained above.

Has the Scottish government carried out any review of the description of cleaner fish in the introductory paragraph quoted above?

The answer to your question is that no review of the description of cleaner fish as quoted by you above has been undertaken.

We would like to clarify that cleanerfish use, including wild and farmed wrasse and lumpfish, are among a number of sea lice management measures employed by some production companies to manage sea lice in farmed salmon.

In particular, what estimation exists of 'total industry demand'?

The Scottish Government understands that levels of demand for cleanerfish by the farmed salmon sector can fluctuate and we can confirm we are not aware of any current estimates of industry demands.

In answering your request we did however, find two historic, internal documents from 2018 & 2019 that made reference to an estimate from a research article titled ‘Use of lumpfish for sea-lice control in salmon farming: challenges and opportunities’ and was published in ‘Reviews in Aquaculture’ by Powell in 2018. In the article Powell estimated that “10 M cleaner fish will be required for UK aquaculture by 2020”.

However, this prediction may not have reflected the actual demand for cleanerfish by 2020 and the Scottish Government makes no current inference of industry demand from this estimate.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.